Case Document 104 Filed in TXSB on 12/02/16 Page 1 of 3

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1 Case Document 104 Filed in TXSB on 12/02/16 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION IN RE: NORTHSTAR OFFSHORE GROUP, LLC, DEBTOR. CASE NO (Chapter 11) (Emergency Hearing Requested) SUBSTITUTE COUNSEL AND WITHDRAW APPEARANCE THIS MOTION SEEKS AN ORDER THAT MAY ADVERSELY AFFECT YOU. IF YOU OPPOSE THE MOTION, YOU SHOULD IMMEDIATELY CONTACT THE MOVING PARTY TO RESOLVE THE DISPUTE. IF YOU AND THE MOVING PARTY CANNOT AGREE, YOU MUST FILE A RESPONSE AND SEND A COPY TO THE MOVING PARTY. YOU MUST FILE AND SERVE YOUR RESPONSE WITHIN 21 DAYS OF THE DATE THIS WAS SERVED ON YOU. YOUR RESPONSE MUST STATE WHY THE MOTION SHOULD NOT BE GRANTED. IF YOU DO NOT FILE A TIMELY RESPONSE, THE RELIEF MAY BE GRANTED WITHOUT FURTHER NOTICE TO YOU. IF YOU OPPOSE THE MOTION AND HAVE NOT REACHED AN AGREEMENT, YOU MUST ATTEND THE HEARING. UNLESS THE PARTIES AGREE OTHERWISE, THE COURT MAY CONSIDER EVIDENCE AT THE HEARING AND MAY DECIDE THE MOTION AT THE HEARING. EMERGENCY RELIEF HAS BEEN REQUESTED. IF THE COURT CONSIDERS THE MOTION ON AN EMERGENCY BASIS, THEN YOU WILL HAVE LESS THAN 21 DAYS TO ANSWER. IF YOU OBJECT TO THE REQUESTED RELIEF OR IF YOU BELIEVE THAT THE EMERGENCY CONSIDERATION IS NOT WARRANTED, YOU SHOULD FILE AN IMMEDIATE RESPONSE. REPRESENTED PARTIES SHOULD ACT THROUGH THEIR ATTORNEYS. SUBSTITUTE COUNSEL AND WITHDRAW APPEARANCE Page 1 of 3

2 Case Document 104 Filed in TXSB on 12/02/16 Page 2 of 3 TO THE HONORABLE MARVIN ISGUR, UNITED STATES BANKRUPTCY JUDGE: The above-captioned debtor, Northstar Offshore Group, LLC (the Debtor ), files this Emergency Motion for Leave to Substitute Counsel and Withdraw Appearance (the Motion to Substitute ) and respectfully states as follows: 1. On August 12, 2016, Montco Oilfield Contractors, LLC, Alliance Offshore, LLC, and Alliance Energy Services, LLC filed an involuntary petition for relief under chapter 11 of title 11 of the United States Code (the Bankruptcy Code ) against the Debtor thereby commencing the above-captioned bankruptcy case. 2. Attorneys from Winston & Strawn LLP subsequently appeared on the Debtor s behalf. See Minute Entry, Aug. 19, 2016; Dkt. No. 20. However, since no order for relief has been entered in this matter, the Court has not yet approved the retention of Winston & Strawn LLP pursuant to section 327(a) of the Bankruptcy Code. 3. The Debtor now wishes to substitute Diamond McCarthy, LLP ( Diamond McCarthy ) as counsel in this matter, and requests the Court s permission to allow such law firm to file its appearance and act on behalf of the Debtor, and to allow Winston & Strawn LLP and all Winston & Strawn LLP attorneys to withdraw their appearances on behalf of the Debtor. 4. Diamond McCarthy has filed (or will promptly file) a separate application for employment as counsel for the Debtor pursuant to Bankruptcy Code 327(a) and Local Rule (a). 5. The Debtor respectfully requests that this Court enter an Order granting the relief requested herein and such other and further relief to which the Debtor may be justly entitled. SUBSTITUTE COUNSEL AND WITHDRAW APPEARANCE Page 2 of 3

3 Case Document 104 Filed in TXSB on 12/02/16 Page 3 of 3 Dated: December 2, 2016 Respectfully submitted, /s/ Lydia T. Protopapas WINSTON & STRAWN LLP Lydia T. Protopapas Texas Bar No Southern Dist. of Texas Bar No Jason W. Billeck Texas Bar No Southern Dist. of Texas Bar No lprotopapas@winston.com jbilleck@winston.com 1111 Louisiana, 25th Floor Houston, TX Telephone: (713) Facsimile: (713) Counsel for Northstar Offshore Group, LLC /s/ Kyung S. Lee DIAMOND McCARTHY, LLP Kyung S. Lee Texas Bar No.: klee@diamondmccarthy.com Charles M. Rubio Texas Bar No.: crubio@diamondmccarthy.com Christopher R Murray Texas Bar No.: cmurray@diamondmccarthy.com Two Houston Center 909 Fannin, 15th Floor Houston, TX Telephone: (713) Facsimile: (713) Proposed Counsel for Northstar Offshore Group, LLC SUBSTITUTE COUNSEL AND WITHDRAW APPEARANCE Page 3 of 3

4 Case Document Filed in TXSB on 12/02/16 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION IN RE: NORTHSTAR OFFSHORE GROUP, LLC, DEBTOR. CASE NO (Chapter 11) ORDER GRANTING MOTION FOR LEAVE TO SUBSTITUTE COUNSEL AND WITHDRAW APPEARANCE The Court has considered the Motion for Leave to Substitute Counsel and Withdraw Appearance ( Motion to Substitute ) filed by the above-captioned debtor, Northstar Offshore Group, LLC (the Debtor ). The Court finds that: (a) it has jurisdiction over the matters raised in the Motion to Substitute pursuant to 28 U.S.C. 1334(b); (b) this is a core proceeding pursuant to 28 U.S.C. 157(b)(2); (c) the relief requested in the Motion to Substitute is in the best interests of the Debtor and its estate, creditors, equity security holders, and other parties in interest; (d) proper and adequate notice of the Motion to Substitute and the hearing thereon has been given and no other or further notice is necessary; (e) the relief granted herein is necessary to avoid immediate and irreparable harm to the Debtor s estate; and (f) good and sufficient cause exists for the granting of the relief requested in the Motion to Substitute. Therefore, it is ORDERED that the Motion to Substitute is granted. It is further ORDERED that Diamond McCarthy, LLP is granted leave to file its appearance on behalf of the Debtor. It is further

5 Case Document Filed in TXSB on 12/02/16 Page 2 of 2 ORDERED that Winston & Strawn LLP and all Winston & Strawn LLP attorneys are withdrawn as counsel for the Debtor and hereby relieved and discharged of any further duty or obligation as counsel to the Debtor Dated:, 2016 UNITED STATES BANKRUPTCY JUDGE